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Trey Mansfield v. City of Murfreesboro
706 F. App'x 231
| 6th Cir. | 2017
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Background

  • Trey Mansfield, a Murfreesboro K-9 officer, sued the City under Title VII and the FLSA claiming he was denied promotion to K-9 Sergeant in retaliation for protected activity (joining a proposed FLSA collective action about mealtime pay, complaining about schedule changes, and participating in an internal sex-discrimination investigation).
  • Major Hudgens had a history of making profane and hostile remarks directed at Mansfield; Hudgens submitted interview questions but recused himself from the promotion board.
  • The City announced a K-9 "Sergeant" position; eight applicants applied (including Mansfield and Sergeant Wood, who was already a Sergeant in another unit).
  • A seven-member interview board ranked candidates and computed point scores: Wood ranked first overall and was ultimately selected; Mansfield ranked fourth.
  • Mansfield alleged the process was a sham and that Hudgens and others hand-picked Wood; the City defended the selection as based on leadership and legitimate non-retaliatory reasons.
  • The district court granted summary judgment for the City; the Sixth Circuit majority affirmed, concluding Mansfield had no direct evidence and failed to show pretext under McDonnell Douglas. Judge Moore dissented, arguing sufficient circumstantial evidence created a genuine dispute on pretext.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether court has jurisdiction to hear appeal while consolidated companion case remains pending Beil precedent: consolidation by court leaves actions separate so appealable Consolidation might defeat finality Court: jurisdiction exists under Beil — appealable final order
Whether Mansfield has direct evidence of retaliation Chief Chrisman’s remark that Mansfield was "openly, vocally critical" proves retaliatory motive Remark requires inferential step; not direct evidence linking protected activity to decision No direct evidence; inferential leap required
Whether Mansfield made a prima facie case of retaliation (causation) Temporal proximity, pattern of hostile treatment, and other facts support causal link Selection occurred >1 year after some events; City argues lack of causal nexus Court assumed prima facie case without deciding, then proceeded to McDonnell Douglas
Whether City’s stated reasons for selecting Wood were pretextual Shifting explanations, overheard comment about "coming up with a good reason," Hudgens’ misconduct and influence show pretext Wood chosen for leadership; lateral transfer allowed; insufficient proof Hudgens controlled selection or that reasons were false Court: City articulated legitimate reasons and Mansfield failed to show pretext; summary judgment for City affirmed. Dissent would reverse and remand on pretext question

Key Cases Cited

  • McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for circumstantial discrimination/retaliation claims)
  • Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard and allocation of burdens)
  • Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (summary judgment—no genuine issue if record could not lead rational jury to find for nonmovant)
  • Univ. of Tex. Sw. Med. Ctr. v. Nassar, 570 U.S. 338 (causation standard for retaliation: but-for causation)
  • DiCarlo v. Potter, 358 F.3d 408 (definition and scope of direct evidence in discrimination cases)
  • Laster v. City of Kalamazoo, 746 F.3d 714 (Title VII retaliation elements)
  • Adair v. Charter County of Wayne, 452 F.3d 482 (FLSA retaliation framework)
  • Dodd v. Donahoe, 715 F.3d 151 (standard of review for summary judgment in Sixth Circuit)
Read the full case

Case Details

Case Name: Trey Mansfield v. City of Murfreesboro
Court Name: Court of Appeals for the Sixth Circuit
Date Published: Aug 7, 2017
Citation: 706 F. App'x 231
Docket Number: Case 16-6613
Court Abbreviation: 6th Cir.